Aug 15 2018

OIG Report Updates

OIG Report: Outpatient Physical Therapy Services

Outpatient physical therapy has been under considerable scrutiny by Medicare for many years. Demonstrating its continued focus on therapy services, the Office of the Inspector General for the Department of Health and Human Services (OIG) released a report of an audit which found that 61% of sampled Medicare claims between July and December 2013 did not comply with rules requiring that services be medically reasonable and necessary, be submitted with proper coding, or submitted with sufficient documentation.1 Providers of outpatient physical therapy services should closely review the report and consider using its metrics for reviewing services billed to federal health care programs.


OIG Report: Cardiac Device Credits

The Office of Inspector General for the Department of Health and Human Services (OIG) recently issued a report that identified significant overpayments related to cardiac device warranty credits. Cardiac devices generally have lifetime warranties which provide hospitals with a full or partial credit for the cost of the failed or recalled device or with a replacement device at no cost. When a hospital receives one of these credits, federal rules typically require a reduction in any in-patient or out-patient payment by Medicare. An OIG report released earlier this year1 reviewed 296 hospital claims involving warranty credits for cardiac devices and none of the claims were properly adjusted to reflect those credits, resulting in a $4.4 million overpayment to the subject hospitals. Hospitals that perform cardiac procedures should consider incorporating this OIG report into their compliance risk assessment process.

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Jul 26 2018

OIG Work Plan Monthly Updates (April, May, and June 2018)

von Briesen continues to monitor the United States Department of Health and Human Services, Office of Inspector General (the "OIG") Work Plan to provide insight into emerging legal trends in health care through blog posts and Legal Updates, such as this one. Health organizations are advised to use the Work Plan to identify the OIG's areas of interest and enforcement priorities, and to review and update policies and procedures accordingly.

To stay informed of monthly Work Plan updates, please visit the von Briesen Health Law Blog and the OIG Work Plan page.

This Legal Update summarizes some of the significant OIG Work Plan updates released for April, May, and June 2018.

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